Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:07-cv-00160-EGB

Document 16

Filed 05/12/2008

Page 1 of 1

IN THE UNITED STATES FEDERAL COURT OF CLAIMS J.O.A. CONSTRUCTION CO., INC., A Michigan corporation Plaintiff V THE UNITED STATES. Defendant Case Number: 07-160C Senior Judge Brugginlk

PLAINTIFF'S MOTION FOR AN ENLARGEMENT OF TIME Plaintiff respectfully requests as enlargement of time of 31 days, to and including June 12, 2008, within to file its Response to Defendants Motion to Dismiss in Part. The Response is presently due May 12, 2008. This is Plaintiff's first request for an enlargement of time for this purpose. Plaintiff's counsel has contacted Defendant's counsel, who has no objection to the granting of an enlargement of time as requested. This motion is necessary for the Plaintiff's counsel to complete the preparation of its response. Plaintiff's counsel has been out of the country for several weeks during the time allowed for the production of the Response and counsel has underestimated the time required to complete the preparation of such Response. For these reasons Plaintiff respectfully requests that the Court grant its motion for a 31 day enlargement of time to file its Response to Defendants Motion to Dismiss in Part . May 12, 2008 /s/ John K. Grylls JOHN K. GRYLLS Attorney for Plaintiff 18430 Mack Avenue Grosse Pointe Farms, MI 48236 Tel: (313) 885-0123 Fax: (313) 886-7699